Opinion
7462-21S
07-08-2022
AMELIA BHATNAGAR & RAJIV BHATNAGAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy, Special Trial Judge
Upon due consideration of respondent's Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed September 10, 2021, pursuant to Rule 40 and for cause, it is
Rule references are to the Tax Court Rules of Practice and Procedure.
ORDERED that, on or before August 8, 2022, petitioners shall file an objection, if any, to respondent's motion. It is further
ORDERED that, on or before August 8, 2022, petitioners may file a proper amended petition that contains clear and concise assignments of each and every error that petitioners allege to have been committed by the Commissioner in the determination of the deficiency in dispute in this case, and clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rule 34(b); Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).
Failure to comply with this Order may result in the granting of respondent's motion and dismissal of this case or other appropriate action by this Court.